The following is a condensed version of Uxbridge and South Ruislip MP John Randall's response to the Department for Transport (DfT) consultation on High Speed Two (HS2). 1. Do you agree that there is a strong case for enhancing the capacity and performance of Britain’s inter-city rail network to support economic growth over the coming decades? I fully agree with the objective of enhancing rail capacity and supporting economic growth. There is undeniably a need to provide an enhanced capacity and performance for the UK rail network. It is clear that rail passenger numbers are increasing, and as such, capacity must meet this demand. However, although I am in favour of the principle of high-speed rail, I am not in support of the plans in their current form. HS2 is simply not the answer to improved rail services and economic growth. There are other alternatives, which I believe have not been properly considered or looked at in enough detail. There is substantiated evidence contained in a report developed by Atkins for DfT that indicates increasing capacity on the West Coast Main Line with the Rail Package 2 (RP2) alternative will meet and exceed the forecast capacity demand. Furthermore, the current plans are severely weighted towards there being a Heathrow spur – something which has not been consulted on. This is something which is of paramount interest to myself and my constituents. There is far from sufficient detailed or indeed accurate information even for the first phase let alone after, and it is impossible to agree with HS2 as so much information is absent. Greater transparency is needed in this process for it to be regarded as fair and representative. It is also worth noting that one of the main claims is that HS2 will help bridge the North-South divide. I fear that HS2 could in fact worsen this divide. The business case shows that seven out of 10 jobs created by high-speed rail will be in London, not the Midlands or North of England. Most of the jobs claimed will not be genuinely new employment, but moved from other areas within that region. Furthermore, HS2 would affect the service sector, where London dominates. Since 70 per cent of HS2 passengers are leisure travellers and there is much greater growth in trips to London (than from London), it is not the regions that will gain. Similarly, cities such as Hull and Coventry in the North that are in need of the economic benefits that a high-speed rail could possibly bring, in virtue of their location, will reap no benefits whatsoever, even though the taxes of people living there will be going towards the lines construction. 2. Do you agree that a national high speed rail network from London to Birmingham, Leeds and Manchester (the Y-network) would provide the best value for money solution for enhancing rail capacity and performance? I would not agree that the Y-network provides best value for money. At a cost of £32bn, and not operational until at least 2033, it is clear that alternatives should be evaluated that can provide better value for money and sooner. This should be a priority. The benefits of the Y-network are based on assumptions that are lacking evidence. The benefit-cost ratio (BCR) for HS2 is a serious cause for concern, not least because it has fluctuated considerably since HS2 was first publicised in 2009. In HS2 Ltd's report to the previous government of December that year, the BCR for HS2, without wider economic impacts, was said to be 2.4. This was restated in the Government Command Paper of March 2010. By the time the consultation documents were published in February 2011, less than 12 months later, the BCR had dropped to 1.6. This is a significant reduction in economic viability. The problem is that we are asked to judge this project on the basis of figures projected over very long periods. HS2 would not be operational for at least 15 years. Economic growth forecasts are constantly changing, passenger number predictions are notoriously inaccurate for such projects and the environmental damage is played down. More disturbing are changes in demand figures. The business case for HS2 depends upon the numbers of passengers who are likely to use it and on the wider figures about future demand for rail services. While the rate of projected demand growth has slowed, by basing the business case on what might happen over the next 35 years, and using out of date forecasting factors, there has still been a great overestimation of demand for long-distance train services. Furthermore, perhaps one of the most disturbing assumptions made by DfT in calculating the economic value of time savings made by HS2 was that originally no account was taken of people working while travelling. Time on a train can now be used productively, so the assumption that time is wasted on a long journey is no longer valid. Given that of the £37bn projected economic benefits of HS2, £25 bn relies upon the benefits to business travellers of journey time savings on HS2, the credibility of these benefits is vital. By February 2011, HS2 Ltd had recognised that arguing this assumption was unsustainable. As a result, they sought to counterbalance it with an assessment of the benefits of reduced crowding which they argue will be a significant advantage of HS2. This raises two main queries – firstly, why was did HS2's significant ability to alleviate crowding not form part of the original case for HS2? Secondly, in relation to this, if the easing of crowding is one of the main benefits of HS2, then this can be done far more quickly, cheaply, effectively, and environmentally by implementing RP2. Furthermore, RP2 is an incremental solution, so it can react to demand and crowd alleviation accordingly. Finally, it is clear that the proposed route and the Y-shaped network have been heavily influenced by the assumption that there should be a link to Heathrow. This has required that the route is to the west of London instead of taking a more direct route northwards. Far from relieving congestion at Heathrow a direct link to the airport will result in an increased demand for flights at Heathrow rather than the other way around. I think that the plans for high speed rail should be reassessed with a view to have a link into Central London without the Heathrow link. 3. Do you agree with the government's proposals for the phased roll-out of a national high-speed rail network, and for links to Heathrow Airport and the HS1 line to the Channel Tunnel? The phased roll out of HS2 arouses a number of queries and scepticism. Firstly, due to the impact it will have on west London, the links to Heathrow should definitely have been included in this London to Birmingham consultation. It is clear that the proposed route has been selected as a result of the location of Heathrow and possibility of a link to HS2 from it. The route, and thus consultation, is incomplete without showing what HS2’s intentions are for the rest of the phases. Furthermore, with the Heathrow Express and the Piccadilly line providing adequate capacity to transport airline passengers into London, it is difficult to see the benefit to capacity in building a link to Heathrow. The completion of Crossrail will also change the position dramatically. Secondly, in a similar vein, there is little to no information on the Phase 2 route from Birmingham to Manchester/Leeds. Although this consultation is scheduled for 2012, I feel by agreeing to Phase 1, one includes their consent to the Y-route. It is also worth noting that travel to the continent from any city other than London is simply not viable. With cheap and convenient air travel, it is simply impractical to travel from say Manchester/Leeds to Paris or Brussels on any means other than plane. Likewise, to reach Scotland from London, the speed and price of air travel is unbeatable. Therefore, although a connection to HS1 seems logical, information on the justification for such costs is not adequately provided. 4. Do you agree with the principles and specification used by HS2 Ltd to underpin its proposals for new high speed rail lines and the route selection process HS2 Ltd undertook? Constructing a railway for 250mph trains is not justified for a Y-network that will be only 200 miles long. There are already several rail routes from London to the north that could be improved to permit faster, more frequent and more accessible services to more destinations. There are viable improvements to the West Coast Main Line that would deliver improved capacity and performance. Already there are trains capable of 140mph that could be lengthened and are not being used to their full potential. Furthermore, HS2 is not suitable for inter-city travel, as there are insufficient stops to serve any cities other than those listed. This severely restricts the usefulness of the line. Speeds of 200mph or even 180mph are still high-speed by any standards but would permit what I believe would be better routes. It seems the quest for speeds of 250mph neither suits our geography or our needs. Although high-speed trains across Europe reach these speeds, the distances being travelled are far greater, and as such, greater speed is required. It appears that no detailed work has been done to investigate the potential benefits of lower-speed lines. The insistence to design the rail corridor for 250mph trains has limited the route options because of the large radius curves required. With high-speed comes high energy consumption, high noise levels, wide rail corridor requirements, loss of property, loss of agricultural land and degradation of the areas local to the railway. The government has not consulted on route alternatives. I believe there should have at least been a public enquiry on the route selection, and at bare minimum an investigation into the use of slower speeds. The route that has been chosen appears to be heavily weighted towards Heathrow links, and it seems that only minor consideration has been given to environmental impacts. Similarly, high-speed rail was included in the Coalition's programme for government as a means of reducing carbon emissions. However the HS2 Ltd main report published in March 2010 says: "HS2 would not be a major factor in managing carbon in the transport sector." On February 9th 2011, [Secretary of State] Philip Hammond sent a letter to MPs in which he said "our proposed London-West Midlands line is expected to be broadly carbon neutral". It therefore strikes me as somewhat absurd that for a cost of £32bn, HS2 will only be carbon neutral. At such a cost, I would at least expect HS2 to significantly aid in the reduction of carbon emissions. 5. Do you agree that the government's proposed route, including the approach proposed for mitigating its impacts, is the best option for a new high-speed rail line between London and the West Midlands? It strikes me that something on this scale could have utilised a public enquiry in order to gauge opinion on the choice of route. There appears to be no information on road closures, or the impact that the required track works at Euston will have. I believe it is essential that the public is made aware of what exactly is going to happen, and how they and their communities will be impacted once construction begins. In my constituency it is apparent that a sizeable number of domestic and commercial properties will have to be demolished, however residents are completely in the dark about the actual properties involved. Similarly land take from gardens has not been identified at all. This is an intolerable situation and makes it impossible for any meaningful consultation. Furthermore, the environmental mitigation measures are not defined. No formal environmental impact assessment has been undertaken. It appears that none will be forthcoming unless a positive decision is taken to construct HS2. This too, I believe is wholly unsatisfactory. All data to date has been obtained through modelling, with very few site visits. With no environmental impact assessment, the environmental costs of HS2 have not been considered adequately. I have not seen any reference to the detrimental effect on the aquifer in the Chilterns of tunnelling. This is sadly just another example of a seemingly rushed and under researched consultation document being produced for the public which is not fit for purpose. The proposed HS2 route will be going across significant amount of open countryside. There are many important wildlife sites which will be affected and many rich ecosystems which have remained intact for centuries will be destroyed. Although the plans talk about "adequate mitigation", some of the ancient woodlands in particular have existed for millennia – no new planting will be able to compensate for their loss. In the Chilterns alone, 22 public rights of way will be impacted, and further afield along the route, 474 hectares of ancient woodland will be affected. In the Colne Valley too valuable wildlife areas are severely affected. Similarly, the increased noise levels will be intrusive and new for residents living close to the line. I have visited the ARUP Soundlab, and am now all too aware of the inadequate noise mitigation my constituents are facing. Upgrading existing infrastructure can be accomplished at a lower cost and with fewer impacts upon the environment. The construction of HS2 will result in large scale disruption, with the rebuilding of Euston Station to allow for the additional lines and lowering the platforms over a seven to eight-year period; the disruption to Crossrail and Great Western services with the building of Old Oak Station; and the disruption of the Chiltern Line service in the area between Northolt and West Ruislip where the two lines run in parallel. 6. Do you wish to comment on the appraisal of sustainability of the government's proposed route between London and the West Midlands that has been published to inform this consultation? The 140-page appraisal does not provide all the information needed to give a comprehensive response to the possible environmental impacts of HS2. I am concerned that there has been no offer of certainty that the noise mitigation to be provided if HS2 is to be built will be to the level and effectiveness sought by those affected. Another issue is that of accessible information on noise contours for those living near the proposed line is not available. Instead there exists a set of maps identifying properties affected by some noise from HS2, marked in grey, and properties affected to such a degree that extra sound insulation would need to be provided for them, marked in yellow. The difficulty here arises in that the properties marked in grey may be affected by anything between an additional 3db to 17db of HS2-related noise, above an assumed baseline level of 50db for every location along the line. The assumed baseline level will inevitably be inaccurate for many locations. Furthermore, no information is available for those whose properties are marked as affected about where in the range of 3-17db of extra noise their specific property may fall. It should also be noted that more detailed information regarding the assessments of extra noise may be available when the Environmental Impact Assessment is published, but this will be after the consultation period has ended. My final comment is that the proposed operating hours for HS2 are extensive. There is still a lack of clarity for those living near the line concerning the possible level of activity on the line during the night. 7. Do you agree with the options set out to assist those whose properties lose a significant amount of value as a result of any new high speed line? I have maintained in my response to this consultation that although I am in favour of the principle of high speed rail, I am not in favour of its current HS2 guise. Nevertheless, if the route does go ahead as planned, I steadfastly want to ensure that those whose properties are directly and significantly affected by a new line must be properly compensated for their resultant loss. With the absence of a definitive compensation scheme, information on the options for dealing with reductions in property values is severely lacking. It is frankly absurd to expect those likely to be financially disadvantaged by a new high-speed line to comment comprehensively on the consultation without knowing what compensation may be available for its adverse impact on them. It also concerns me that compensation will not be available until 2027. Residents are going to begin to be fully affected from 2015 onwards when construction commences, but won’t see a penny until 2027. Blight has already become a very real factor in Hillingdon and I have been informed that there is already evidence that house prices are falling near to the proposed rail corridor. Any scheme designed to compensate affected property owners effectively must allow them to choose the time and reasons for selling that property. If this is not the case, the hardships caused by HS2 will remain unaddressed. The paramount objective of a long term compensation scheme must be to offer reassurance to property owners and prospective buyers that the scheme will restore property prices in affected areas to HS2-unaffected market values. In summary there are too many elements of the proposals of HS2 that cause me great concern for me to be able to do anything except reject them. Not least the dramatic and devastating effect on many Hillingdon residents as well as facilities in the borough including the Hillingdon Outdoor Activity Centre (HOAC). I also share the concerns of those elsewhere about the effect on the Chilterns area of outstanding natural beauty. The consultation process has been marred by and in my opinion is therefore deeply flawed by the lack of detail contained in it. The roadshow held in Ruislip far from reassuring residents’ concerns seem to have heightened worries as so many questions have left unanswered. This project is far too an important and costly decision for the country for it to be made without looking at all the options in a serious and detailed way. For a project of this importance it should be trying to get the support of as many of the public as possible. I regret to say that in my opinion this it has palpably failed to do so.